When the 2023 Medicare Physician Fee Schedule (MPFS) was proposed earlier this year it projected a 4.42% cut to the conversion factor (CF), with radiology facing cuts of between 3 – 4% depending on subspecialty. The final rule moves the cut even deeper, with the 2023 CF set 4.47% lower than the 2022 CF.

There is significant activity among physician professional societies, including the American College of Radiology (ACR), Radiology Business Management Association (RBMA), Medical Group Management Association (MGMA), and others, to urge remediation of the cuts. Congressional legislation in the form of H.R. 8800, which has at least 90 co-sponsors, would “extend a payment increase under Medicare's physician fee schedule through the end of 2023 (currently set to expire at the end of 2022).” Interested physicians and practice managers are urged to write their representatives in support of H.R. 8800 and to contact their professional societies.

The Centers for Medicare and Medicaid Services (CMS) estimates the overall impact of the MPFS as follows:

To break it down further, CMS now provides expected impact figures by service location:

Although the conversion factor was reduced from $33.0775 per RVU in the proposed rule to the final figure of $33.0607 per RVU, the proposed rule contained an error in the calculation of the malpractice RVU; once the error was corrected, the final fee schedule improved slightly from the proposed.  

These estimates by CMS are compiled using 2021 claims volume data and 2022 payment rates. Our preliminary review of specific codes shows that a significant number of codes decreased more than the 4.5% CF adjustment, which indicates that their relative values were also adjusted downward by CMS. By far those negative adjustments reflected the technical component of the RVUs and will be felt by practices that bill globally, outside the hospital.

The real impact of the 2023 MPFS can only be understood through an in-depth analysis of the fee schedule using the volume of procedures billed by your practice. Our full volume-weighted analysis will be available as soon as it can be completed.

Medicare Fee Schedule Payment and Valuation Changes

The MPFS contains both payment policy decisions and adjustments to the Quality Payment Program (QPP). Positive changes to 10 radiology-related CPT codes that we reported in our review of the Proposed Rule were finalized, but CT Colonography was not approved for payment as the ACR had requested in its submitted comments.

Telehealth flexibilities that were put into place during the public health emergency (PHE) were extended, including:

• Services may be furnished in any geographic area and in any originating site setting, including the patient’s home.
• Certain services may be provided via audio-only telecommunications systems.
• Services may be billed with the place of service (POS) indicator that would have been reported had the service been furnished in-person.

These policies will be in effect for 151 days following the end of the PHE. The PHE declaration is renewed in 90-day increments, and currently runs through January 11, 2023. There is every expectation that it will be extended until at least April 2023.

Quality Payment Program (QPP) Changes

MIPS Value Pathways

2023 will be the first year MIPS Value Pathways (MVP) will be available for reporting. CMS finalized 5 new MVPs, as follows:

1. Advancing Cancer Care
2. Optimal Care for Kidney Health
3. Optimal Care for Patients with Episodic Neurological Conditions
4. Supportive Care for Neurodegenerative Conditions
5. Promoting Wellness

These add to the 7 MVP’s that were previously approved, but which have been updated:

1. Advancing Care for Heart Disease
2. Optimizing Chronic Disease Management
3. Advancing Rheumatology Patient Care
4. Improving Care for Lower Extremity Joint Repair
5. Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
6. Patient Safety and Support of Positive Experiences with Anesthesia
7. Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes

After reviewing the details of all 12 pathways, the only one we found that might be useful for radiology is Optimal Care for Patients with Episodic Neurological Conditions. Review our article for more information about how MVPs will work.

Traditional MIPS

Changes were made to the measures and activities in the Quality and Improvement inventories, but no substantial changes were made to the Cost or Promoting Interoperability categories.

Quality Measures

CMS reports that there will be a total of 198 Quality Measures available for the 2023 performance year, which will impact payments in 2025. There will be 9 new Quality Measures, including 1 new administrative claims measure; 1 composite measure; 5 high priority measures; and 2 new patient-reported outcome measures. Of the new Quality Measures, Screening for Social Drivers of Health could be relevant to radiology.

Eleven (11) Quality Measures will be removed, 4 fewer than proposed. One of the removed measures (#76: Prevention of Central Venous Catheter (CVC)-Related Bloodstream Infections) will affect radiology practices. In addition, there were substantive changes to many existing Quality Measures.

Administrative claims measures will be scored exclusively against performance period benchmarks, and the definition of a high-priority measure has been expanded to include health equity-related measures.

Improvement Activities

Four (4) new Improvement Activities have been added, 6 existing activities were removed, and 5 existing activities were modified.   The Improvement Activity changes will not affect most radiology practices. 

Scoring and Weighting

The category weighting will remain the same as it is for 2022, as will the Data Completeness Threshold of 70%. The Performance Threshold will continue to be 75 points, but 2022 is the final performance year for the Exceptional Performance Bonus. The range of payment adjustment will continue to be +/- 9%.

Several QPP provisions that were previously finalized by CMS will take effect in 2023. They include:

• The web reporting interface will no longer be available after the 2022 performance year.
• Measures with a benchmark will no longer have a 3-point floor; they will fall within a range of from 1 to 10 points.
• Measures without a benchmark will receive 0 points, except small practices (fewer than 15 clinicians) will continue to receive 3 points.
• Measures that do not meet the case minimum will receive 0 points, except small practices (fewer than 15 clinicians) will continue to receive 3 points. Measures calculated from administrative claims are excluded from scoring if the case minimum is not met.

The scoring changes listed above do not apply to new measures or administrative claims measures for the first two years in which they are available for use.

Complete information on the Quality Payment Program is available for download from CMS.

Conclusion

Our annual impact analysis of the MPFS valuation changes will be finalized over the coming weeks. As noted, many healthcare advocacy groups are lobbying Congress to intervene to avoid the planned 4.47% fee schedule cut, either in the pending legislation or separately as it has done at the last minute in recent years. We will keep our readers apprised of any such changes that occur. Subscribe to this blog for the latest information. 

Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.

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